Every attack will be a crit if you are facing Penance, as he only has 10 luck. Crit % is rather simple in X being that its entirely based on luck, (Crit % = Users luck - Enemies luck) which given that they are facing Penance I am assuming it will be at least 100 higher.
Besides, 3m HP is not very much in the great scheme of things.
We have been discussing Penance the entire time lol.






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